ETHICAL CHANNEL

In order to ensure compliance with its Code of Conduct, GHESA is offering its interest groups an Ethics Box to allow
them to report and provide information and documentation on any possible irregularity or illegal behaviour by way of the internet,
so that the Compliance Committee can initiate an investigation. The report may include any documentation that is deemed appropriate.

GHESA guarantees that the IT tools used in the process will maintain the confidentiality and preserve the identity of the reporting
party, which will not be transmitted to the reported party without the former’s approval. This will guarantee that the identity of
the reporting party remains unknown and thus avoid any kind of possible retaliation from the reported party.

In any event, communications shall always observe principles of truthfulness and proportionality.
This system cannot be used for any purposes other than those implemented to ensure compliance with the GHESA Code of Conduct.

FORM

Marked fields with * are required

Are you a GHESA employee?

Yes No

Do you wish to file a complaint regarding one or more of the members of the GHESA Compliance Committee?

Legal Notice

GHESA®, Ingeniería y Tecnología S.A., domiciled in Madrid (Spain), registered in
the “Registro Mercantil” in the province of Madrid, Volume 293, in the “libro de sociedades”,
page 122, sheet nº. M.5898, Inscription 144ª – N.I.F. (Spanish tax identification code): A28126274,
guarantees scrupulous respect for current regulations on Personal Data Protection in the terms specified
in the law: “Ley Orgánica 15/1999”. In accordance with the L.O. 15/1999, you are hereby informed
and give your consent to the incorporation of your data in automated files and automated treatment
of the said files by GHESA® Ingeniería y Tecnología, S.A. for statistical purposes and communication
including electronic marketing in accordance with Article 21 of Law 34/2002 regarding Information
Society Services, “Servicios de la Sociedad de la Información”.Likewise, in agreement with current
legislation, we inform you that the submission of you personal data is voluntary, and you can refuse
to supply said data without adverse consequence to yourself. We also inform you that you can exercise
your rights of access, rectification, cancellation and opposition, by contacting us in writing at: GHESA®
Ingeniería y Tecnología, S.A. Calle Magallanes, 3-9ª, 28015 MADRID - Phone: 91 309 81 00, Fax: 91 594 24 28.

Privacy Policy

General Information

GHESA , Ingeniería y Tecnología S.A., domiciled in Madrid (Spain), constituted in Madrid in presence of the Notary Public D. Ramón Corral Beneyto, registered in the “Registro Mercantil” in the province of Madrid, Volume 293, in the “libro de sociedades”, page 122, sheet nº. M.5898, Inscription 144ª – N.I.F. (Spanish tax identification code): A28126274 (henceforth GHESA) is the owner of the Web Site located in the Domain www.ghesa.com.

The Privacy Policy, described as follows, is only applicable to the said Web Site, to be understood as such all the pages and sub-pages included in the Domain www.GHESA.com., GHESA declining any responsibility on different privacy policies and personal data protection contained in Web Sites accessible by hyperlinks located in the said Web Site and not directly controlled by GHESA.

GHESA wishes to inform the users of this Web Site that the present declaration reflects the policy regarding data protection followed by GHESA. This policy has been configured with scrupulous respect for current regulations regarding personal data protection, i.e., among others, in the terms specified in the law: “Ley Orgánica 15/1999”, Personal Data Protection, dated December 13th, (henceforth referred to as LOPD) and the Royal Decree “Real Decreto 994/1999”, of 11th d June, approving the Regulations on security measures on automated files containing personal data (henceforth referred to Regulation 994/1999).

Collection of personal data

GHESA does not voluntarily collect data of personal nature pertaining to users of this Web Site. The only data requested from Users are those provided voluntarily in filling out different forms in the Web Site. Consequently GHESA only uses personal data provided voluntarily by users. Only in this case, when desired by the User, and always voluntarily, personal data may be communicated to GHESA.

Said data provided voluntarily by the user may be incorporated in automated files, registered with Spanish Data Protection Agency, “Agencia Española de Protección de Datos” controlled by GHESA. Consequently, the User who voluntarily provides GHESA with personal data expressly authorises treatment of said data with the exclusive purpose of administration of the condition of registered user of GHESA support services.

In all cases, collected data will always be treated in accordance with the current regulations regarding personal data protection.

Security Measures

Personal data supplied by the User to GHESA may be stored in automated or other data bases, for which GHESA is responsible, and assumes all technical, organizational and security measures which guarantee confidentiality, integrity and quality of the information therein contained in accordance with the LOPD and in Regulation 994/1999. Communications between GHESA and Users do not use secure channels and transmitted data are not encrypted so, consequently, Users are requested not to provide sensitive personal data, as in terms of Article 7 of the LOPD, as security measures applicable in insecure channels make this unadvisable.

Purpose of data treatmen

Personal data communicated voluntarily by the User are destined solely to the concrete purpose of administration of the condition of registered user of the support service and will be treated with complete confidentiality, destined only to those purposes for which they were provided and of which the User is expressly informed at the moment of data collection in this Privacy Policy.

Data disclosure

Personal data collected at this Web Site will not be disclosed to third parties or companies, except to persons and concrete conditions in that the said disclosure is protected by the LOPD Users providing personal information hereby consent to the incorporation of this information in personal data files, for which GHESA is responsible, as well as of their possible use by GHESA, for marketing purposes, of GHESA products, in strict accordance with current legislation regarding Information Society Services, regarding commercial communications, except in the case of User’s request to the contrary. Likewise, the User who voluntarily communicates his data to GHESA via this Web Site expressly consents to the utilization of said personal data for marketing information, including by electronic means by companies affiliated to GHESA included in the Web Page http://www.ghesa.com/ingles/avisolegal.html in strict agreement with current legislation concerning personal data protection and Information Society Services except in the case of User’s request to the contrary. Data quality: access rights, opposition, rectification and cancellation. GHESA is committed to safeguard at all times the personal data voluntarily provided by users of this Web Site, updated, such that they correspond to the true identity and personal characteristics of said users. Consequently any User may at any time exercise his/her legal rights for access, rectification or cancellation of personal data if so desired, by means of written communication to GHESA